GLOBAL POLICY EMPLOYEES & SOCIAL MEDIA Guidelines for appropriate behavior on social media
Document at final approval stages
Principles and rules addressed to Group employees regarding their behavior on external Social Media 1
Respect copyright and fair use laws
2
Be careful when you present yourself online
3
Be mindful when communicating with your audience
4
Safeguard confidential information and the privacy of others
5
Be responsible for protecting UniCredit’s reputation
6
Use common sense
The matrix below is designed to help ensure appropriate behavior on social media platforms.
CRITICAL*
YES
Avoid commenting Confer with the Social Media Country Team or local I&C structure regarding the topic Upon approval, comment on the topic in the manner agreed upon
Do not comment NO
RELATED TO YOUR CURRENT JOB
Report the matter to the Social Media Country Team or the local I&C structure
NON-CRITICAL
State that you do not represent UniCredit position but are offering your own opinion State that you are an expert in the field and give your current job title Share your opinion in a way that does not undermine UniCredit ’s reputation Use the interaction to expand your knowledge and your network
State that you do not represent UniCredit ‘s position but are offering your own opinion State that you are not an expert in the field Use the interaction to expand your knowledge and your network
REPUTATIONAL RISK (particularly topics relating to senior management, life inside the company, products, services, shareholders, commercials and ad campaigns, etc.) *Only UniCredit’s Key Communicators or Media Relations are permitted to comment on critical topics, as indicated in “Dealing with Media,” our Group’s Global Media Policy.
Document at final approval stages: the document has been shared with and reviewed by the functions and the
entities listed in the introduction table. It’s about to start the publishing steps in UniCredit SpA as Global Policy
2
GLOBAL POLICY EMPLOYEES & SOCIAL MEDIA Guidelines for appropriate behavior on social media
Competent Function: IDENTITY & COMMUNICATIONS Unit: Group Internal Communications
Date: < Month, Year >
Release: < N, X >
Please fill out the below “Classification level”, indicating in according to the confidentiality’s degree of the content, one of the following Levels: Public, Internal Use Only, Confidential, Strictly Confidential. For more details refer to Internal Regulation n. 526E Document at final approval stages: the document has been shared with and reviewed by the functions and the
entities listed in the introduction table. It’s about to start the publishing steps in UniCredit SpA as Global Policy
3
Principles and rules addressed to Group employees regarding their behavior on external social media
Subject
Responsible function of the Document
Group Internal Communications
Group Brand Management Group Media Relations Group Sustainability CEE Identity & Communications GI&C Project Management & Budget Coordination Labour Policies and Industrial Relations Human Capital Development Global Multichannel & Business Innovation Group Operational & Reputational Risks Operational and Administrative Risks & Processes Group Regulatory Counsel Security Department – ICT Security Governance COO and Support CLs Organization & Processes
Actors involved in the sharing process
Entity
UniCredit Bank AG (Identity& Communications, CIB Communications) Bank Pekao (Identity & Communications) Bank Austria (Identity & Communications, CEE HR) YapıKredi Bank Azerbaycan QSC (Identity & Communications) UniCredit Bank Banja Luka & UniCredit Bank d.d. (Identity & Communications) UniCredit Bulbank (Identity & Communications) Zagrebačka banka d.d. (Identity & Communications) UniCredit Bank Czech Republic and Slovakia, a.s. (Identity & Communications) UniCredit Bank Hungary Zrt. (Identity & Communications) UniCredit Tiriac Bank (Identity & Communications) AO UniCredit Bank (Identity & Communications) UniCredit Bank Serbia (Identity & Communications) UniCredit Bank Slovenia (Identity & Communications) Yapı ve Kredi Bankası A.Ş (Identity & Communications) UniCredit Bank Ukraine - PJSC “Ukrsotsbank” (Identity & Communications)
Approved by
CEO Federico Ghizzoni
Addressed to
All Legal Entities
Document at final approval stages: the document has been shared with and reviewed by the functions and the
entities listed in the introduction table. It’s about to start the publishing steps in UniCredit SpA as Global Policy
4
SUMMARY
1
2
PURPOSE AND SCOPE OF APPLICATION
6
1.1
Purpose
6
1.2
Scope of application
8
BUILDING A CULTURE OF APPROPRIATE SOCIAL MEDIA BEHAVIOR
9
2.1
General principles for participating in online channels and social media
11
2.2
Respect copyright and fair use laws
11
2.3
Be careful when you present yourself online
12
2.4
Be mindful when communicating with your audience
12
2.5
Safeguard confidential information and the privacy of others
13
2.6
Be responsible for protecting UniCredit’s reputation
13
2.7
Use common sense
15
3
LISTENING
16
4
CONTACTS
17
Document at final approval stages: the document has been shared with and reviewed by the functions and the
entities listed in the introduction table. It’s about to start the publishing steps in UniCredit SpA as Global Policy
5
1
PURPOSE AND SCOPE OF APPLICATION
1.1 Purpose This This document integrates the Group regulation for UniCredit S.p.A. (hereafter “UniCredit” or the “Holding Company”) and for the Group Companies (hereafter also “Legal Entities” or “Companies” and, jointly with “UniCredt S.p.A.”, the “Group”) that UniCredit S.p.A., in its role as Holding Company, in compliance with current laws and regulations,1 and in coherence with the Group managerial coordination system defined by the “Group Managerial Golden Rules”, issues in the interest of the stability of the Group and with the aim to ensure a consistent management of the entrepreneurial plan and the overall functioning of the same. In this context, this document has the aim of defining principles and rules for accessing and interacting on external social media, to be applied by the employees of the Group in their online activities both inside and outside the workplace. Please note that this Policy should apply when the employees identify themselves in the social media as UniCredit employees or are, in any case, known/or recognizable as such and their actions can have a negative impact on UniCredit’s reputational or business sides. As such, the general principles given below are designed to explain, in a friendly and collegial manner, how all employees,2 whenever they wish to engage in external social media, must do so with respect and responsibility3 for their roles as UniCredit employees. All employees are consequently required to adhere to this Policy, as well as to any supplementary rules specified by the Legal Entities. In addition to the present Policy, UniCredit has established an internal regulation framework to ensure that social media are used in a coherent and coordinated manner, in keeping with UniCredit’s values and principles as well as the Group’s overall activities.4 To obtain more information please see the following documents, which are referred to in the following pages:
•
Global Policy “Group Principles and Rules for Social Media Communications”, which provides governance principles regarding the management of social media channels in pursuing branding and/or business purposes, to be applied by the Legal Entities of the Group;
1 - In particular, Article 61 of Legislative Decree n. 385 of 1° September 1993 (“Italian Banking Act”) and the “Supervisory Instructions” issued by the Bank of Italy. 2 - The present document applies to employees, consultants and collaborators, all of whom must comply with these guidelines and all legal requirements at the Group and local levels. Please refer to your UniCredit contract and nondisclosure agreement that you have signed for further information regarding our Group’s guidelines and employee rules. 3 - Principles and guidelines on how to behave on internal social media (OneNet Enterprise Social Network) are provided by “OneNet Terms of Use and Netiquette,” available on OneNet for colleagues with access. 4 - The principles that should direct and guide us in our daily business are set forth in the UniCredit Integrity Charter and in the Code of Conduct.
Document at final approval stages: the document has been shared with and reviewed by the functions and the entities listed in the introduction table. It’s about to start the publishing steps in UniCredit SpA as Global Policy
6
1
PURPOSE AND SCOPE OF APPLICATION
•
•
Global Policy “Dealing with Media”, which defines principles and rules for the management of Media Relations that make clear to each business structure who is authorized to communicate with the media and when,5 for and on behalf of the Group or using the Group’s name in events and corporate dealings that may in any way influence public opinion of the Group’s image; Global Policy “Event, Incident and Crisis Management Plan” which details the management process, skills, techniques and information related to emergency/crisis status, with the aim of protecting company assets.
The current Global Policy is not intended to be a comprehensive guide to all legal and regulatory obligations as well as ethical concerns that may arise when using social media, but rather a list of principles to be followed; it must be read in conjunction with the related, more detailed rules and procedures. For the majority of the above obligations UniCredit has established specific internal regulations not addressed in this Policy, but to which the reader should refer directly to ensure compliance with those regulations. The reader should refer in particular to regulations regarding the use of electronic devices, the Internet and email, the management of security matters, information disclosure6, improper commercial activities, etc. These issues have been cited here as non-limiting examples and do not lessen the need to adhere to any applicable internal or external regulations.
5 - The term “media” refers to communication tools such as press agencies, newspapers and periodicals, television and radio as well as all other electronic/digital communication channels, including the Internet and all social media (e.g., websites, blogs, newsletters and sites such as Facebook, Twitter, YouTube, Google Plus, Pinterest and Instagram). 6 - Merely by way of example and not comprehensive, refer to the following Global Rule: “Secure Management of Information”.
Document at final approval stages: the document has been shared with and reviewed by the functions and the entities listed in the introduction table. It’s about to start the publishing steps in UniCredit SpA as Global Policy
7
1
PURPOSE AND SCOPE OF APPLICATION
1.2 Scope of application This document is directly applicable to UniCredit S.p.A. and is addressed to all the Legal Entities of the Group and shall be applied in compliance with legal requirements and regulations locally in force. Should some of the predictions contained in this document be less restrictive than the local law, the Group Company will adopt the local regulations in force and more restrictive. The adoption of this document will be subject to monitoring by Group Internal Communications and the Digital Internal Communications team in particular. The Companies of the Group are therefore expected to start promptly – after diligent assessment and approval by their relevant Competent Bodies – the necessary activities aimed at the correct application of the present document. Should the Company consider: • •
the present Global Policy as not applicable, or necessary to make changes/exceptions to the provisions contained in this Global Policy for compliance with the local regulations (if more restrictive) or because of organizational/ operational constraints,
the Company will have to submit to the function Group Internal Communications a Non Binding Opinion request, in compliance with the provisions of the current Group regulation.7
7 - “Principles for the Management of the Global Rules.”
Document at final approval stages: the document has been shared with and reviewed by the functions and the entities listed in the introduction table. It’s about to start the publishing steps in UniCredit SpA as Global Policy
8
2
BUILDING A CULTURE OF APPROPRIATE SOCIAL MEDIA BEHAVIOR
Social media are changing the way we work and how we engage with our colleagues, customers and other stakeholders. As an increasingly important tool, social media complement traditional communication and business channels to help us build stronger, more successful relationships, starting with our customers. UniCredit is undertaking activities to fully integrate social media channels within the digital strategy of the Group and is leveraging them to support brand engagement and communication, business and customer care. For this purpose, dedicated workgroups have been identified across the Group in order to manage UniCredit’s presence on social media. In general, each of us may access social media for personal purposes and – if aligned with the regulations of the Legal Entity – also for professional purposes. This situation means that UniCredit must build a culture of appropriate social media behavior and maintain clear guidelines that define how we should conduct ourselves online when we address content related to UniCredit or topics related to economics or the financial sector. The growing prevalence of social media means that most of us are likely to be connected to online networks, blogs, wikis or other virtual environments, where lines between our personal and professional lives are easily blurred. Thus, the general principles listed below are designed to explain how the participation of employees on social media has to be respectful and responsible, in particular when addressing content related to UniCredit or economic and financial topics. These principles apply to any online content relating to UniCredit, its people, products and services that may be commented on, without reference to the social media used – i.e., whether that media consists of UniCredit’s official pages on Facebook, YouTube, Twitter, etc., or any external social media platform – and regardless of the device used to access the social media. They apply whether you are using social media via a company-issued device provided by your Legal Entity or via your personally owned devices (e.g., computers or smartphones), and they will help to minimize legal liability for you and the Group. UniCredit’s policies and guidelines relating to the behavior of employees apply to your online activities both inside and outside of the workplace, and whether or not you identify yourself in those activities as a UniCredit employee.8
The values of UniCredit’s Integrity Charter – fairness, transparency, respect, reciprocity, freedom to act and trust fully apply to activities on the web. Behaviors that might have a negative reputational or business impact may result in disciplinary action.
8 - For example, they apply when you share content on LinkedIn through your personal account, when you tweet your opinions on Twitter, and when you upload a video on YouTube.
Document at final approval stages: the document has been shared with and reviewed by the functions and the entities listed in the introduction table. It’s about to start the publishing steps in UniCredit SpA as Global Policy
9
2
BUILDING A CULTURE OF APPROPRIATE SOCIAL MEDIA BEHAVIOR
Remember: how we act individually reflects who we are collectively as a Group. However, activities both inside and outside the workplace that adversely affect your UniCredit job performance, the performance of others, or UniCredit’s legitimate business and reputational interests are a proper focus for company policy. With this in mind, we must be mindful that each employee of the Group may play different roles: • •
using external social media may be part of his or her job responsibility. In this case, the employee must refer to UniCredit’s internal regulation framework on the use of social media;9 or they may make personal use of external social media.10
In both cases the employee may use his or her personal social network profile to interact with both: • •
the Group’s official pages (channels/online activities operated by the Group); the general digital environment (channels/online activities not operated by the Group).
Under these circumstances, whatever channel you may be using, related or not to the Group, it will be necessary to use good judgment. This is because the Internet makes it easy for others to associate and link our profiles with that of the Group. To be sure to maintain compliant behavior, please refer to chapter 2.1 of this document. The strategy and activities required to build a culture of appropriate social media behavior among employees are coordinated at two levels:
• •
at the Group level, by Group Internal Communications in tandem with the Social Media Lab (SML);11 at the local level, by the local Internal Communication teams in tandem with the Social Media Country Team (SMCT)12 and other relevant local functions.
9 - Please refer to Global Policy “Group Principles and Rules for Social Media Communications” and to Global Policy “Dealing with Media” 10 - The use of social media during working hours and/or via workplace equipment may be restricted according to national regulations. 11 - The Social Media Lab is a cross-functional group that ensures central coordination of UniCredit’s social media governance model. Its role is to define the approach and strategy for the Group’s presence on social networks, to develop and disseminate common guidelines aimed at ensuring that the social network presence is in line with the strategy, and to share internal and external best practices. The SML is composed of social media leaders that include representatives of the following internal functions: Communications, Business and IT. It is coordinated by the Social & Digital Branding team. The SML can be contacted at
[email protected]. 12 - The Social Media Country Team is a cross-functional group that exists in the Legal Entities of each country; it manages local social media activities. The SMCT in Italy can be contacted at
[email protected].
Document at final approval stages: the document has been shared with and reviewed by the functions and the entities listed in the introduction table. It’s about to start the publishing steps in UniCredit SpA as Global Policy
10
2
BUILDING A CULTURE OF APPROPRIATE SOCIAL MEDIA BEHAVIOR
2.1 General principles for participating in online channels and social media, in respect of UniCredit’s reputation If you choose to participate in online channels and social media activities, it is important that you understand what is asked, expected from you and required of you, whether you are engaging in those activities inside or outside of the workplace. You are free to identify yourself as a UniCredit employee in your online personal profiles. But when you identify yourself as a UniCredit employee or other online content identifies you as one, you are connecting yourself to your coworkers, supervisors and even UniCredit’s customers. You should thus ensure that the content associated with you is consistent with UniCredit policies. A general recommendation for your behavior on online channels and social media is to use common sense and be aware that whatever you do or write could persist indefinitely on these channels and spread without limit. In addition, when the subject at hand concerns UniCredit, its products and services, or even the industry and the framework in which the Group operates, we ask you to follow the principles below in connection with your participation in any form of social media.
2.2 Respect copyright and fair use laws Be sure to protect yourself and UniCredit by respecting all copyright and fair use laws. These laws are in place to protect your personal rights as well as those of the Company. Here are some points to remember when creating a personal online account, profile, group or community:13 •
•
if you mention that you are a UniCredit employee, be certain to indicate that your personal profile, website or group is not managed or endorsed by our Group in any way (for example, do not use the official UniCredit logo, do not explicitly state or imply that the page or group is an official one, do not repost information from official sources on an external site.), and indicate that the opinions expressed are your personal ones. If you want to insert a link to a UniCredit profile, make sure that you select the official one on each channel. (If support is needed, please refer to SML or SMCT); if you would like to use UniCredit’s branding, logo or images or those of its Legal Entities in any way, you will need to request and receive official authorization from the Social Media Lab (if you are in the Holding Company) or your Social Media Country Team (if you work for other Legal Entities).
13 - If you run a personal website, blog or forum on topics related to UniCredit’s business (e.g., finance, banking, partnerships), please refer to the policy “Dealing with Media.”
Document at final approval stages: the document has been shared with and reviewed by the functions and the entities listed in the introduction table. It’s about to start the publishing steps in UniCredit SpA as Global Policy
11
2
BUILDING A CULTURE OF APPROPRIATE SOCIAL MEDIA BEHAVIOR
Content also matters. Whenever you link, embed or “retweet” text from an official UniCredit online channel or social media platform, remember that your actions could affect UniCredit’s reputation among your audience members. Please pay particular attention to the context (where and when the content is being republished or shared), and do not spam your audience.
2.3 Be careful when you present yourself online You should always bear in mind possible consequences before you act online. You never know when your content might be read by your colleagues, managers, customers or other UniCredit stakeholders. It is also important to remember that most online platforms have rules in place to protect their users. Familiarize yourself with their terms and conditions before introducing yourself to and participating in online platforms or communities.
2.4 Be mindful when communicating with your audience Our Group has well-established policies in place to communicate with the public. Read them and follow them. Only our designated UniCredit officials and media relations officers have the authority to speak on behalf of our Group (identified as “Key Top Communicators” and “Key Specialist Communicators”). Please refer to UniCredit’s Global Media Policy “Dealing with Media,”14 for more information. When you post, publish or tweet online content related either to the banking sector or to UniCredit and its products and services, we recommend doing the following:
•
•
• • •
•
consider your level of expertise and the reputational risks associated with discussing anything online in an open forum, as your opinions might be associated with the official UniCredit position on a certain topic; if you comment on topics that are within your area of expertise, always mention that your comments are your own. To make sure of this, we would recommend that you use the following disclaimer: “The content and comments on this site are my own and do not necessarily represent UniCredit’s positions, strategies or opinions”; inform your audience of your UniCredit affiliation and job title; never share information related to internal activities or your professional relationships; never provide suggestions on specific UniCredit products or on customer activities involving the Group or your Legal Entity, or comment on legal disputes or specific customer complaints involving UniCredit; never post UniCredit links sent from a suspicious source, a practice known as phishing.15
14 - “Global Policy – Dealing with Media” provides a framework that defines applicable rules concerning how to communicate with the media. 15 - Phishing is a fraudulent attempt to steal personal information, usually through email or social networks. Phishing messages are designed to look legitimate, and users are asked to provide their personal details.
Document at final approval stages: the document has been shared with and reviewed by the functions and the entities listed in the introduction table. It’s about to start the publishing steps in UniCredit SpA as Global Policy
12
2
BUILDING A CULTURE OF APPROPRIATE SOCIAL MEDIA BEHAVIOR
2.5 Safeguard confidential information and the privacy of others Take extra care to protect UniCredit and its stakeholders (e.g., colleagues, managers, senior managers, collaborators). Work-related activities call for discretion, and you are expected to follow suit. This means that you are never to reveal confidential company information or sensitive commercial information; inside information (as defined by regulations on market abuse) regarding, but not limited to, UniCredit’s revenues, future plans and strategies; or information and personal data relating to our customers, colleagues, suppliers or partners.16 If you are unsure as to whether information is confidential, check with your manager or the relevant functions first (see also paragraph “Use common sense”). Please refrain from speculating on the topics above, regardless of whether you identify yourself online as a UniCredit employee.
2.6 Be responsible for protecting UniCredit’s reputation If you come across an online discussion, post or feed that may negatively impact our Group’s reputation, please take a moment to consider the situation and the implications of that content for yourself and for UniCredit. We recommend that you do not take any personal action, but instead inform your manager, your SML if you work at the Holding structure or your SMCT if you work at another Legal Entity, in the following instances:
16 - In greater detail, as a general rule, when participating in social media, it is strictly forbidden to disclose: • confidential company information, i.e., information and news related to UniCredit and/or the Group that are not in the public domain and that are subject to restrictions on their distribution and disclosure in accordance with applicable internal rules; • sensitive commercial information, such as confidential information (i.e., non-public information within the Group or any information provided by an external source on the assumption that it will be kept confidential and used solely for the purpose for which it was provided) and/or strategic information for the business and information that might influence competitors’ actions; • inside information as defined by regulations, included internal regulations, on market abuse; • information and personal data relating to customers and/or employees, except after obtaining specific and express consent of those concerned, in compliance with the legislation on data protection; • information and data that fall within the scope of the law on banking secrecy. • In relation to the above (by way of example only) specific internal regulations were enacted, to which reference is made for application purposes (Global Policy “Group Principles and Rules for Social Media Communications” Paragraph 2).
Document at final approval stages: the document has been shared with and reviewed by the functions and the entities listed in the introduction table. It’s about to start the publishing steps in UniCredit SpA as Global Policy
13
2
BUILDING A CULTURE OF APPROPRIATE SOCIAL MEDIA BEHAVIOR
•
• • •
you come across a blog or online forum discussing UniCredit, its products and services, which may have a negative impact on our Group, even if you are an expert on the subject matter; you see improper use of UniCredit’s branding, images, trademarks or documents, or encounter damaging remarks or false accounts of UniCredit managers; you discover inaccurate information about UniCredit, its products and services or people on a public site, blog or other social media; you encounter blogs, online forums or social networking posts that include incorrect UniCredit web addresses, particularly those related to our multichannel sites, tools and apps.
The matrix below is designed to help ensure appropriate behavior on social media platforms:
CRITICAL*
YES
Avoid commenting Confer with the Social Media Country Team or local I&C structure regarding the topic Upon approval, comment on the topic in the manner agreed upon
Do not comment NO
RELATED TO YOUR CURRENT JOB
Report the matter to the Social Media Country Team or the local I&C structure
NON-CRITICAL
State that you do not represent UniCredit position but are offering your own opinion State that you are an expert in the field and give your current job title Share your opinion in a way that does not undermine UniCredit ’s reputation Use the interaction to expand your knowledge and your network
State that you do not represent UniCredit ‘s position but are offering your own opinion State that you are not an expert in the field Use the interaction to expand your knowledge and your network
REPUTATIONAL RISK (particularly topics relating to senior management, life inside the company, products, services, shareholders, commercials and adv campaigns, etc.)
*Only UniCredit’s Key Communicators or Media Relations are permitted to comment on critical topics, as indicated in “Dealing with Media,” our Group’s Global Media Policy.
Document at final approval stages: the document has been shared with and reviewed by the functions and the entities listed in the introduction table. It’s about to start the publishing steps in UniCredit SpA as Global Policy
14
2
BUILDING A CULTURE OF APPROPRIATE SOCIAL MEDIA BEHAVIOR
There are two issues to take into consideration when you encounter or publish content related to UniCredit on social media: your current professional status as an employee and the reputational risk associated with the content itself. The proper action to take in such cases depends upon the significance of the information:
•
•
critical content: content related either to the banking sector or to UniCredit and its products or services and, in general, all content that could affect the reputation of the Group and its stock market valuation; content that could generate or be tied to crisis situations;17 non-critical content: content related either to the banking sector or to UniCredit and its products or services without any relevance to its reputation or its stock market valuation..
2.7 Use common sense Above all, we request that you pause before you publish, and ask yourself: Is this appropriate? Is this in line with UniCredit’s social media guidelines and policies? Does it generate positive value for my personal or professional branding and/or perceptions of the Group? If you are unsure, talk to your manager, SML/SMCT or your local I&C structure first. Be judicious, because once you share your content, you are on the record. Your actions online will be accessible via search engines for longer than you think.
The values underscored in UniCredit’s Integrity Charter – fairness, transparency, respect, reciprocity, freedom to act, and trust – influence our conduct and how we behave in our daily work environment; they also apply to how we conduct ourselves online.
17 - For a more detailed description of crisis management in UniCredit please refer to “Event, Incident and Crisis Management Plan“ and its annexes.
Document at final approval stages: the document has been shared with and reviewed by the functions and the entities listed in the introduction table. It’s about to start the publishing steps in UniCredit SpA as Global Policy
15
3
LISTENING
Due to the importance of social media to our business activities, reputation, branding and, in general, our relationships with many stakeholders, each Legal Entity of the Group can implement listening activities on the Web and on its own external social media accounts for content related to UniCredit. Other users of the Web can also notice and draw attention to the behavior of people who present themselves as UniCredit’s employees that are not in line with this Policy’s principles.18 Any online activities by employees that deviate from the principles of this Policy will be addressed in accordance with local policies and regulations. If inappropriate or if proscribed, the activity should be reported to the SML or SMCT. If such a report is made by a Web user who is external to the Group to an internal function,19 then this function shall convey the report to the SML or SMCT without delay. If the topic is considered to pose a reputational risk to the Group or its people, the SML or SMCT will: • •
determine and implement the best solution, such as requesting the removal of the published content, carrying out an online intervention, or taking no further action; initiate, when needed, interaction with the employee in question (e.g., informational, instructional, disciplinary) and in collaboration with the competent Human Resources and/or Internal Communications functions, depending on the topic and the type of incident.
18 - Listening and monitoring activities related to social media are addressed in the following Global policies: “Group Principles and Rules for Social Media Communications” and “Dealing with Media”. 19 - Some examples of possible points of contact include call centers, email addresses, letters or emails of complaint, and reports to local branch directors.
Document at final approval stages: the document has been shared with and reviewed by the functions and the entities listed in the introduction table. It’s about to start the publishing steps in UniCredit SpA as Global Policy
16
4
CONTACTS AND RESOURCES
For clarifications on our present regulation or for support with operational aspects of the processes prescribed by the regulation, interested functions or Legal Entities may refer to the Holding Company’s Structure Group Internal Communications (GI&C department), for which contact information is provided in the following table. Additional information, documentation, research materials, updates and training information about “Employees & Social Media” are available on the Group Intranet.
Clarification on the content of this document Fabio Delton - Digital Internal Communications e-mail:
[email protected] Letizia Chlapoutakis - Digital Internal Communications e-mail:
[email protected] Claudio Zucca - Digital Internal Communications e-mail:
[email protected]
Operational assistance Social Media Lab e-mail:
[email protected] Social Media Country Team Italy e-mail:
[email protected]
Document at final approval stages: the document has been shared with and reviewed by the functions and the entities listed in the introduction table. It’s about to start the publishing steps in UniCredit SpA as Global Policy
17
